Module 3 Overview Video
Video coming soon: complete the reading below to continueGold Aviation Services is a FAA Part 135 on-demand air charter operator based at KFLL, operating under South Florida FSDO-19. Our SMS is implemented under 14 CFR Part 5: the FAA's mandatory SMS regulation for Part 135 certificate holders.
The SMS is structured around four key roles:
- Accountable Executive (AE): ultimate accountability for the SMS. Has authority over resources required to implement and maintain the system. Signs the safety policy.
- Director of Safety (DOS): day-to-day management of the SMS. Administers the reporting system, manages the corrective action process, conducts audits, and maintains SMS records.
- Director of Maintenance (DOM): ultimate regulatory authority for maintenance. Participates in the SAG and ensures maintenance-related hazards are addressed.
- Department Representatives: designated individuals from Flight Ops, Maintenance, and Management who participate in the Safety Action Group.
Safety Action Group (SAG): Meets regularly to review safety reports, assess risk, recommend corrective actions, and monitor open corrective actions. The SAG is the operational heart of our Safety Assurance process.
Safety Board: Chaired by the Accountable Executive. Meets quarterly to review safety performance data, SPI trends, audit results, and SAG recommendations. Provides organizational direction on safety priorities and resource allocation.
The Gold Aviation voluntary safety reporting system is the primary mechanism for hazard identification. You can submit a report for any safety concern: near-miss, hazard observation, operational error, equipment issue, or unsafe condition: at any time.
How to submit: Reports are submitted through the Gold Safety SMS platform. The Director of Safety is your point of contact for all safety reports.
What to report:
- Any near-miss or unplanned event that could have resulted in injury, damage, or loss
- Any hazard you observe: in operations, maintenance, facilities, or process
- Errors you made or observed that could recur
- Organizational conditions (pressure, fatigue, communication failures) that are creating safety risk
- Anything that didn't feel right: even if nothing went wrong
What happens after you report:
- The Director of Safety acknowledges your report
- The report is classified by hazard type and risk level
- If corrective action is required, a corrective action is opened and assigned in Gold Safety
- The SAG reviews the report and monitors the corrective action to closure
- You may be contacted for additional information: this is part of the process, not an investigation of you
14 CFR §5.71 14 CFR §5.75 14 CFR §5.21 AC 120-92B §7
The Flight Risk Assessment Tool (FRAT) is a mandatory pre-departure risk assessment required for every company flight leg. No flight may depart without a completed and submitted FRAT. The FRAT does not replace PIC judgment: it supplements it by requiring formal evaluation of defined risk factors and triggering escalation and approval requirements when risk thresholds are met.
Scoring methodology (CPP §10.3): The FRAT uses a binary methodology: each risk factor is either present (1) or absent (0). The cumulative number of selected risk factors determines the overall risk level across categories including weather, crew condition and experience, aircraft status, airport and environmental complexity, passenger or mission-related factors, and operational pressure factors.
Risk levels and required actions:
- Low risk: Operations may proceed. FRAT must be documented prior to departure.
- Medium risk: Review contributing factors and implement mitigations. Do not depart without approval from personnel authorized to exercise operational control as defined in company OpSpecs. Mitigations and approval must be documented.
- High risk: Do not depart without operational control approval. A mitigation plan and crew briefing are required and must be documented. The Director of Safety must be notified.
Multi-leg flights: For multi-leg or extended duty periods, the FRAT must be re-evaluated prior to each departure when conditions have changed: including changes in weather, crew status (rest, fatigue, illness), aircraft status (MEL/CDL items), or airport/environmental conditions. A new FRAT record is created for each re-evaluation.
SIC delegation (CPP §10.2G-H): The PIC may delegate FRAT completion and submission to the SIC. However, the PIC retains full responsibility for the accuracy, completeness, and execution of the FRAT. When delegated, the PIC must review the FRAT before departure, verify the identified risk factors accurately reflect actual conditions, and confirm all required mitigations, notifications, and approvals are complete. Both crew members maintain awareness of the assessed risk level: the SIC must raise discrepancies to the PIC before departure.
Oversight and performance: The Director of Safety administers the FRAT program, monitors data trends, and integrates findings into the SMS. The Chief Pilot ensures pilot compliance and supports escalation discipline. FRAT completion rate of 95% (FRATs completed per legs flown) is a Gold Aviation Safety Performance Indicator: meaning your FRAT compliance is tracked at the organizational level and reported to the Safety Board.
CPP §10.1–10.3 AC 120-92B §5.2 14 CFR §5.71 Gold Aviation SMS Manual §5.10
Just culture in flight operations means you can report errors, near-misses, and hazards without fear of automatic discipline. But it also means you are expected to use that protection responsibly: to surface safety information that helps the organization learn.
In practice, this means:
- If you make a mistake: report it. A self-reported error is handled very differently from a discovered unreported one.
- If you observe a colleague engaging in at-risk behavior: report it. The just culture framework applies to your report, not just your own conduct.
- If you feel pressure (from scheduling, dispatch, or management) that is causing you to take shortcuts: that is reportable. Organizational pressure is a systemic hazard.
- Removal from duty for fitness concerns is a protected act. If you remove yourself from a flight for safety reasons, that decision is supported by Gold Aviation Services' safety policy.
14 CFR §5.21 AC 120-92B §7
As a pilot or flight attendant at Gold Aviation Services, your SMS responsibilities under 14 CFR Part 5 and the Gold Aviation SMS Manual include:
- FRAT completion: complete the Flight Risk Assessment Tool before every flight. If your score indicates High risk, do not depart without notifying the Director of Safety and implementing mitigations.
- Fitness to fly: you have a personal and regulatory obligation to assess your own fitness before every flight. Fatigue, illness, medication effects, and psychological stress are all disqualifying if they impair your ability to safely perform your duties. I'M SAFE is a useful self-assessment tool.
- Hazard and incident reporting: submit a safety report for any near-miss, unusual occurrence, unstable approach, go-around, ATC deviation, bird strike, or other safety-relevant event. Same-day reporting is strongly preferred.
- CRM and assertiveness: speak up. If you observe something that concerns you: at any phase of flight, regardless of who is PIC: you are expected and empowered to raise it.
- Safety meetings and training: attend Safety Action Group meetings when invited, complete all assigned SMS training modules by the due date.
14 CFR §91.3 14 CFR §5.71 AC 120-92B §5 Gold Aviation SMS Manual §5.10
Understanding what happens after a report is submitted helps reinforce why reporting matters: and what to expect if you are involved in a follow-up.
When a safety report or audit finding identifies a hazard that requires action, a corrective action is opened in the Gold Safety platform. Corrective actions are the mechanism Gold Aviation Services uses to document, assign, track, and close the response to identified safety risks. This is distinct from the Continuing Analysis and Surveillance System (CASS), which is a maintenance quality program under AC 120-79A led by the Director of Maintenance.
The corrective action process:
- Initiation: DOS opens a corrective action in Gold Safety, assigns a number, links it to the originating report or finding, and documents the hazard and risk level
- Investigation: root cause is identified. Contributing factors are documented.
- Corrective action: a specific action is assigned to a responsible party with a due date
- Implementation: the assigned party completes the corrective action
- Verification: DOS verifies the action was completed and effective
- Closure: The corrective action is closed with documentation of the action taken and effectiveness verification. The SAG reviews and concurs.
You may be contacted by the DOS during the investigation phase for additional information. This is a normal part of the process: it is not an investigation of you personally, and it does not affect your just culture protections.
14 CFR §5.75 14 CFR §5.77 Gold Aviation SMS Manual §5.9
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